United States Fourth Circuit

A trust's investment-advice fees are not fully deductible under Internal Revenue Code section 67(e), but are subject to the 2% floor established by section 67(a).

Appellate Information

• Decided 05/01/2003
• Published 05/01/2003

Judges

• Before LUTTIG, TRAXLER, and KING, Circuit Judges.

Court

• United States Fourth Circuit

Counsel

• For Appellees:
  
• ARGUED:Ronald David Aucutt, McGuireWoods, L.L.P., McLean, Virginia, for Appellants.  Gilbert Steven Rothenberg, Tax Division, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF:Craig D. Bell, McGuireWoods, L.L.P., Richmond, Virginia, for Appellants.  Eileen J. O'Connor, Assistant Attorney General, Paul J. McNulty, United States Attorney, Anthony T. Sheehan,Tax Division, United States Department of Justice, Washington, D.C., for Appellee.